On March 20, 2025, the Government promulgated Decree No. 70/2025/ND-CP, amending and supplementing several provisions of Decree No. 123/2020/ND-CP dated October 19, 2020, which governs invoices and documents. Among the amended provisions are specific cases in which electronic invoices (e-invoices) may no longer be used.
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Photo 1: 10 circumstances for suspension of E-invoice usage effective from June 1, 2025 _Hotline: 0972 118 764
Pursuant to Clause 1, Article 16 of Decree No. 123/2020/ND-CP (as amended and supplemented by Decree No. 70/2025/ND-CP), enterprises, economic organizations, other entities, business households, and business individuals shall cease using e-invoices with or without a tax authority’s authentication code, or e-invoices generated from cash registers, under the following circumstances:
(1) Enterprises, economic organizations, other organizations, business households, and individual business entities shall have their tax identification numbers invalidated;
(2) Enterprises, economic organizations, other organizations, business households, and individual business entities are classified as cases in which the tax authority has conducted verification and issued a notice confirming that they are not operating at their registered business address;
(3) Enterprises, economic organizations, other entities, business households, and individual businesspersons that have temporarily suspended their business operations; temporarily ceased the use of e-invoices in accordance with a written notification submitted to the tax authority (Form No. 01/ĐKTĐ-HĐĐT, Appendix IA issued together with Decree No. 70/2025/NĐ-CP); or business households and individual businesspersons that have switched from the declaration-based tax calculation method to the presumptive method or per-occasion tax payment method as notified by the tax authority;
(4) Enterprises, economic organizations, other entities, business households, and business individuals are subject to a notification from the tax authority on the suspension of e-invoice usage for the purpose of tax debt enforcement;
(5) In the event that e-invoices are used in transactions involving smuggled goods, prohibited items, counterfeit products, or goods infringing intellectual property rights, and such violations are detected and reported to the tax authority by a competent authority;
(6) In cases where e-invoices are issued for the purpose of fictitious sales of goods or provision of services to appropriate funds from organizations or individuals, as detected, prosecuted, and notified to the tax authority by a competent agency; and where the police, the People’s Procuracy, or the Court issues a written request for the tax authority to suspend the use of e-invoices by the said organization or individual;
(7) In cases where the business registration authority or another competent state agency requests an enterprise to temporarily suspend its conditional business lines upon discovering that the enterprise fails to meet the statutory business conditions, or in cases where a competent authority detects and notifies the tax authority that the taxpayer has committed violations of tax or invoice regulations;
(8) Enterprises, economic organizations, other entities, business households, and business individuals using e-invoices generated from cash registers who change their business lines in a manner that no longer satisfies the conditions for using cash registers e-invoices as prescribed in this Decree shall be subject to a notice from the tax authority requiring the taxpayer to cease the use of e-invoices generated from point-of-sale systems;
(9) During the course of inspection or examination, if the tax authority determines that the taxpayer has committed tax evasion, has been established for the purpose of illegal trading or use of e-invoices, or has unlawfully used e-invoices to evade taxes as prescribed by law, the tax authority shall issue a notice to cease the use of e-invoices; the taxpayer shall be subject to legal sanctions in accordance with the provisions of Decree No. 70/2025/ND-CP;
(10) In cases where the taxpayer is classified as having a very high risk level according to the taxpayer risk assessment, the tax authority shall suspend the use of e-invoices in accordance with the provisions of Decree No. 70/2025/ND-CP.
Photo 2: 10 circumstances for suspension of E-invoice usage effective from June 1, 2025 _Hotline: 0972 118 764
In summary, to minimize cases of suspension from using e-invoices, enterprises, economic organizations, other entities, household businesses, and individual businesspersons must fully comply with the regulations on the use of e-invoices under the current 2019 Law on Tax Administration by: consistently issuing e-invoices with complete and accurate information upon the sale of goods or provision of services; registering to use e-invoices generated from point-of-sale systems connected to the tax authority (if applicable); and ensuring compliance with the regulations on electronic transactions, accounting, and taxation. Furthermore, they shall be held responsible for the accuracy of the information stated on the e-invoices.
Decree No. 70/2025/ND-CP amending and supplementing certain articles of Government Decree No. 123/2020/ND-CP dated October 19, 2020, on invoices and documents, shall take effect from June 1, 2025.
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